The President’s authority over the executive branch confers tremendous power, which is

ordinarily constrained by well-established norms as well as legal limitations. Enlisting executive

agencies to funnel U.S. Government funds to benefit the President would pose a fundamental

challenge to our democracy by collapsing the separation between the President’s personal

interests and the vast machinery of the executive branch. This risk extends beyond the baseline

potential for corruption inherent in foreign leaders or representatives perceiving an advantage in

driving revenue to the President’s business. It would also amount to the monetization of the

executive branch by the President of the United States.

FOIA Request to State Department and Agency’s Failure to Respond

21. On January 19, 2018, Plaintiff sent a FOIA request to Defendant State

Department.

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22. In the request, Plaintiff requested records from the State Department regarding:

1. All records relating to the reimbursement . . . of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

2. All records relating to directly booking accommodations . . . at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

3. All records relating to . . . reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

4. All records relating to . . . budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

January 19, 2018

Re: Freedom of Information Act Request

Dear FOIA Officer:

Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. § 552, I hereby request that youroffice produce, within 20 business days, the following records (see below for clarity on the types ofrecords sought):

Bureau of Diplomatic Security (DS)

1. All records relating to the reimbursement by the Bureau of Diplomatic Security (DS) of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

2. All records relating to directly booking accommodations by the Bureau of Diplomatic Security (DS), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

3. All records relating to Bureau of Diplomatic Security (DS) for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

4. All records relating to Bureau of Diplomatic Security (DS) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

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Bureau of Budget and Planning (BP)

5. All records relating to the reimbursement by the Bureau of Budget and Planning (BP) (including but not limited to BP/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

6. All records relating to directly booking accommodations by the Bureau of Budget and Planning (BP) (including but not limited to BP/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

7. All records relating to the Bureau of Budget and Planning (BP) for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

8. All records relating to Bureau of Budget and Planning (BP) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Bureau of International Narcotics and Law Enforcement Affairs (INL)

9. All records relating to the reimbursement by the Bureau of International Narcotics and Law Enforcement Affairs (INL) (including, but not limited to INL/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

10. All records relating to directly booking accommodations by the Bureau of International Narcotics and Law Enforcement Affairs (INL) (including, but not limited to INL/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

11. All records relating to the Bureau of International Narcotics and Law Enforcement Affairs (INL) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017,

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until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

12. All records relating to Bureau of International Narcotics and Law Enforcement Affairs (INL) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Foreign Service Institute (FSI)

13. All records relating to the reimbursement by the Foreign Service Institute (FSI) (including, but not limited to, FSI/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

14. All records relating to directly booking accommodations by the Foreign Service Institute (FSI) (including, but not limited to, FSI/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

15. All records relating to the Foreign Service Institute (FSI) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

16. All records relating to Foreign Service Institute (FSI) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Bureau of International Security and Nonproliferation (ISN)

17. All records relating to the reimbursement by the Bureau of International Security and Nonproliferation (ISN), (including, but not limited to, ISN/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

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18. All records relating to directly booking accommodations by the Bureau of International Security and Nonproliferation (ISN), (including, but not limited to, ISN/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

19. All records relating to the Bureau of International Security and Nonproliferation (ISN) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

20. All records relating to Foreign Service Institute (FSI) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Bureau of Counterterrorism and Countering Violent Extremism (CT)

21. All records relating to the reimbursement by the Bureau of Counterterrorism and Countering Violent Extremism (CT) (including, but not limited to, CT/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

22. All records relating to directly booking accommodations by the Bureau of Counterterrorism and Countering Violent Extremism (CT) (including, but not limited to, CT/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

23. All records relating to the Bureau of Counterterrorism and Countering Violent Extremism (CT) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

4 Case 1:18-cv-01073 Document 1-2 Filed 05/07/18 Page 6 of 10

24. All records relating to Bureau of Counterterrorism and Countering Violent Extremism (CT) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Bureau of Arms Control, Verification and Compliance (AVC)

25. All records relating to the reimbursement by the Bureau of Arms Control, Verification and Compliance (AVC) (including, but not limited to AVC/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

26. All records relating to directly booking accommodations by the Bureau of Arms Control, Verification and Compliance (AVC) (including, but not limited to AVC/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

27. All records relating to the Bureau of Arms Control, Verification and Compliance (AVC) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

28. All records relating to Bureau of Arms Control, Verification and Compliance (AVC) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Bureau of Democracy, Human Rights, and Labor (DRL)

29. All records relating to the reimbursement by the Bureau of Democracy, Human Rights, and Labor (DRL), (including, but not limited to, DRL/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

30. All records relating to directly booking accommodations by the Bureau of Democracy, Human Rights, and Labor (DRL), (including, but not limited to, DRL/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017,

5 Case 1:18-cv-01073 Document 1-2 Filed 05/07/18 Page 7 of 10

until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

31. All records relating to the Bureau of Democracy, Human Rights, and Labor (DRL) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

32. All records relating to Bureau of Democracy, Human Rights, and Labor (DRL) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Bureau of Economic and Business Affairs (EB)

33. All records relating to the reimbursement by the Bureau of Economic and Business Affairs (EB), (including, but not limited to, EB/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

34. All records relating to directly booking accommodations by the Bureau of Economic and Business Affairs (EB), (including, but not limited to, EB/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

35. All records relating to the Bureau of Economic and Business Affairs (EB) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

36. All records relating to Bureau of Economic and Business Affairs (EB) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

6 Case 1:18-cv-01073 Document 1-2 Filed 05/07/18 Page 8 of 10

Bureau of Educational and Cultural Affairs (ECA)

37. All records relating to the reimbursement by the Bureau of Educational and Cultural Affairs (ECA) (including, but not limited to, ECA/EX), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

38. All records relating to directly booking accommodations by the Bureau of Educational and Cultural Affairs (ECA) (including, but not limited to, ECA/EX), at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

39. All records relating to the Bureau of Educational and Cultural Affairs (ECA) policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

40. All records relating to Bureau of Educational and Cultural Affairs (ECA) budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Other Department of State Components

41. All records relating to the reimbursement, by any Department of State component (including but not limited to regional bureaus, e.g., the Bureau of Near Eastern Affairs (NEA)), of foreign officials and diplomats, for stays at the Trump International Hotel in Washington, D.C., from January 20, 2017, until the date that a search is conducted, for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

42. All records relating to directly booking accommodations, by any Department of State component, at the Trump International Hotel in Washington, D.C. on behalf of foreign officials and diplomats, from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

43. All records relating to Department of State policies for reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. This request is for policies effective from January 20, 2017, until the date that a search is conducted for records

7 Case 1:18-cv-01073 Document 1-2 Filed 05/07/18 Page 9 of 10

responsive to this FOIA request. This request includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats.

44. All records relating to Department of State budgeting and accounting of reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C., from January 20, 2017, until the date that a search is conducted for records responsive to this FOIA request.

Request Process 45. In addition to the records requested above, I also request records describing the processing of this request, including records sufficient to identify search terms used and locations and custodians searched and any tracking sheets used to track the processing of this request. If your agency uses FOIA questionnaires or certifications completed by individual custodians or components to determine whether they possess responsive materials or to describe how they conducted searches, I also request any such records prepared in connection with the processing of this request.

FEE WAIVER

FOIA provides that any fees associated with a request are waived if “disclosure of theinformation is in the public interest because it is likely to contribute significantly to publicunderstanding of the operations or activities of the government and is not primarily in the commercialinterest of the requester.” 5 U.S.C. § 552(a)(4)(A)(iii).

I am the Editor-in-Chief of Lawfare, an online publication dedicated to informing public

understanding on operations and activities of the government. Lawfare is published by The LawfareInstitute, a 501(c)(3) not-for-profit educational organization, and in cooperation with The BrookingsInstitution, a 501(c)(3) nonprofit public policy organization. This request is submitted in connectionwith Lawfare’s mission to publish information that is likely to contribute significantly to the publicunderstanding of executive branch activities related to law and national security. Lawfare does not havecommercial interests.

In addition to satisfying the requirements for a waiver of fees associated with the search andprocessing of records, I am entitled to a waiver of all fees except “reasonable standard charges fordocument duplication.” 5 U.S.C. § 552(a)(4)(A)(ii)(II). Federal law mandates that fees be limited todocument duplication costs for any requester that qualifies as “a representative of the newsmedia.” Id. Lawfare is a “news media organization[]” that “gathers information of potential interest toa segment of the public, uses its editorial skills to turn the raw materials into a distinct work, anddistributes that work to an audience.” Nat’l Sec. Archive v. Dep’t of Defense, 880 F.2d 1381, 1387 (D.C.Cir. 1989). We intend to give the public access to documents transmitted via FOIA on our website,https://www.lawfareblog.com, and to provide information about and analysis of those documents asappropriate.

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RESPONSIVE RECORDS

We ask that all types of records and all record systems be searched to discover recordsresponsive to our request. We seek records in all medium and format. This includes, but is not limitedto: agendas, manifests, calendars, schedules, notes, and any prepared documentation for meetings, calls,teleconferences, or other discussions responsive to our request; voicemails; e-mails; e-mail attachments;talking points; faxes; training documents and guides; tables of contents and contents of binders;documents pertaining to instruction and coordination of couriers; and any other materials. We ask thatyou search all systems of record, including electronic and paper, in use at your agency. We also ask thatyou search files or emails in the personal custody of your employees, such as personal email accounts,as required by FOIA and to the extent that they are reasonably likely to contain responsive records. Wewould prefer records in electronic format, saved as PDF documents, and transmitted via email or CD-ROM. We ask that you search for records from all components of the Department of State that may bereasonably likely to produce responsive results.

If you make a determination that any responsive record, or any segment within a record, isexempt from disclosure, we ask that you provide an index of those records at the time you transmit allother responsive records. In the index, please include a description of the record and the reason forexclusion with respect to each individual exempt record or exempt portion of a record, as provided byVaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974). When you deem aportion of a record exempt, we ask that the remainder of the record to be provided, as required by 5U.S.C. §§ 552(a)(8)(A)(ii) & 552(b).

Given the 20-day statutory deadline, we hope to be as helpful as possible in clarifying or

answering questions about our request. Please contact me by phone or email if you require anyadditional information. I appreciate your cooperation, and look forward to hearing from you very soon.

Re: Your FOIA request re the Trump International Hotel

My colleagues Ben and Quinta (CCed) passed along your message regarding our FOIA request on stays at the Trump International Hotel. Thank you for working with us on this request!

We're happy to streamline as you suggest, but would prefer the following slightly more detailed formulation so as to ensure all of the material sought in our original request is still covered:

“I hereby request that the Department of State, including all its bureaus and components, produce any and all records relating to the following:

1. Any stays it has arranged, authorized, budgeted or accounted for, funded, reimbursed, or otherwise facilitated at the Trump International Hotel in Washington, D.C. for foreign officials and diplomats from January 20, 2017 to the present. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.

2. Any policies relating to the reimbursement of, or payment for, hotel accommodations for foreign officials and diplomats visiting Washington, D.C. effective from January 20, 2017 to the present. This includes, but is not limited to, policies regarding the selection of hotel, the cost of accommodations, and procedures relating to the reimbursement or payment on behalf of foreign officials or diplomats."

Of course, this would presumably only replace numbered paragraphs 1-44 of our request. Paragraph 45 relating to "Request Process" documents and the remaining paragraphs relating to a fee waiver and responsive records would still apply.

Does this sound like it would work for you? I am happy to discuss further as needed. My office line is 202-647-2480.

Quinta: I appreciate the thoughtful discussion we were able to have regarding your Trump International Hotel request. As I noted, to begin work on this request and speed its expedition it would be very helpful to us to be able to streamline its wording. It seems to me the information that you would like to have could be obtained by reformulating your request along the following lines into one succinct but inclusive paragraph. Case 1:18-cv-01073 Document 1-3 Filed 05/07/18 Page 4 of 4

“I hereby request that you produce all records kept by the Department of State relating to stays it has facilitated at the Trump International Hotel in Washington D.C. for foreign officials and diplomats from January 20, 2017 to the present. This request includes, but is not limited to, communications, receipts, invoices, itineraries, and billing statements.”

Please note that by referring to the inclusive category of “Department of State” in this reformulation we are by necessity including references to the records of all its bureaus and components that you have cited separately.

If this new formulation is acceptable to you, we will begin to process it right away. Please let me know. Sincerely, Louis